Information Security and Acceptable Use - UTDBP3096
The information assets of The University of Texas at Dallas (UT Dallas) must be administered in conformance with applicable laws and The University of Texas System Board of Regent's Rules and Regulations. Appropriate security controls will be applied based on risk as determined by the potential impact and likelihood of disruptions to the organization's mission, assets, and reputation. This Policy defines UT Dallas organizational expectations for responsible use of UT Dallas Information Systems by building a culture of information security risk awareness and mitigation.
UT Dallas must comply with information security requirements defined by applicable federal and state regulations, UT System policies, and contractual obligations. This includes Texas Administrative Code 202 (TAC 202), University of Texas System 165 (UTS 165), Texas Medical Records Privacy Act, Texas Public Information Act, Family Educational Rights and Privacy Act (FERPA), Health Insurance Portability and Accountability Act (HIPAA), Payment Card Industry Data Security Standard (PCI DSS), Gramm–Leach–Bliley Act (GLBA), the FBI's Criminal Justice Information Services (CJIS) Security Policy, and Digital Millennium Copyright Act (DMCA).
Definitions (alphabetical order)
Confidential Data: The subset of University Data that is private or confidential by law or otherwise exempt from public disclosure (e.g. Social Security Numbers, personally identifiable Medical and Medical Payment information, Driver's License Numbers and other government-issued identification numbers, Education Records subject to the Family Educational Rights & Privacy Act (FERPA), financial account numbers, and/or other University Data about an individual likely to expose the individual to identity theft).
Controlled Data: The subset of University Data that is not created for or made available for public consumption but that is subject to release under the Texas Public Information Act or other laws (e.g. network diagrams, UT Dallas emails, and/or UT Dallas-ID number).
Decentralized IT: UT Dallas employees who report to the heads of business units, departments, or programs and who manage a subset of UT Dallas Information Systems.
Incidental Use: Occasional personal use of UT Dallas Information Systems. Activities related to official duties on behalf of UT Dallas, such as research and teaching, are not Incidental Use.
Information Security Standards: Documented controls specified for specific technology components which, when implemented, reduce risk of compromise (e.g. change default passwords, disable unnecessary services, apply current compatible patches, include in backup scheme)
ISO: The Information Security Office is the UT Dallas department, led by the Chief Information Security Officer, assigned responsibility for promoting confidentiality, integrity, availability, and accountability of information assets.
Mobile computing device: Laptops, tablets, smart phones, or other devices designed to be easily portable that are capable of creating, storing, or processing University Data.
OIT: Office of Information Technology is the UT Dallas department, led by the Chief Information Officer, assigned responsibility for planning and ongoing operation of centrally-provided information systems such as telecommunications networks, computers, software, databases, system integration and hosted solutions.
Public Data: The subset of University Data intended for public consumption (e.g. marketing materials, press releases, public websites, published papers, and/or UT Dallas-issued email address).
University Data: This Policy uses the term University Data to refer to data for which UT Dallas has a responsibility for ensuring appropriate information security or would be liable for data exposure, as defined by applicable law, UT System policy, regulations, or contractual agreements. University Data may include information held on behalf of UT Dallas or created as a result and/or in support of UT Dallas business (e.g. financial records, personnel records, officially maintained student records, and/or records of official UT Dallas committees), including paper records. This definition does not imply, address, or change intellectual property ownership.
User:Any individual granted access to UT Dallas Information Systems, including guests and contractors.
UT System:The University of Texas System
UT Dallas:The University of Texas at Dallas (also referred to as UTD)
UT Dallas Information Systems:All computer and telecommunications equipment, software, data, and media, owned or controlled by UT Dallas or maintained on its behalf.
Intellectual Property Ownership
This Policy does not create or supersede any existing ownership rights to intellectual property. Existing intellectual property ownership rights defined by applicable law, UT System policy, regulations, or contractual agreements do not change based on storage location. UT Dallas personnel who may have access to content in the course of performing job responsibilities do not obtain ownership rights to that content.
Roles & Responsibilities
Appropriate levels of information security can only be achieved with a well-coordinated team effort across the UT Dallas organization. Stakeholders must work together to identify risks and take responsibility for appropriate controls.
ISO: The ISO promotes compliance and transparent discussion of risks associated with UT Dallas Information Systems. The ISO has oversight responsibility including establishing the Information Security and Acceptable Use Policy and related Information Security Standards, testing for compliance, and reporting risk posture to internal and external stakeholders.
Data Owners (DO): The DO is typically the responsible manager of a school or department that collects or is the primary user of a data asset, or the Principal Investigator (PI) on a UT Dallas-managed research project. DOs are responsible for achieving compliance with this Policy, applying for exemptions when justified, and accepting residual risk when security threats cannot be further mitigated. DO responsibilities include approving or denying requests to access their data and periodically reviewing access assignments and taking corrective action if inappropriate access is detected.
Information Security Coordinator (ISC): An ISC is an individual typically designated by a dean or department head to serve as a liaison between the ISO and the DOs.
Data Custodian (DC): The DC is designated by the DO and assists with the ongoing operational tasks of managing information assets. For example, server and application administrators and software developers may be considered DCs.
Data User (DU): DUs are the individuals who the DOs authorized to access a data asset. DUs typically have no role in determining the security requirements for the information asset or performing server or application maintenance. Nonetheless, DUs must understand and abide by the security requirements of the information asset and the expectations of the DO and this Policy.
All University Data is subject to a risk-based data classification standard maintained by the ISO and must be protected accordingly. Classifications are Confidential Data, Controlled Data, and Public Data.
Data classification is the primary factor for establishing necessary security controls. Additional controls may be warranted for systems where integrity, availability, and/or accountability requirements are more critical than the requirements for confidentiality.
UT Dallas Information Systems are provided for the purpose of conducting the business of UT Dallas and/or UT System. However, Users are permitted to use UT Dallas Information Systems for use that is incidental to the User's official duties to UT Dallas or UT System (Incidental Use) as permitted by this Policy.
University Data created or stored on a User's personally owned computers, mobile computing devices, removable storage devices, or in databases that are not part of UT Dallas's Information Systems are subject to Public Information Requests, subpoenas, court orders, litigation holds, discovery requests and other requirements applicable to UT Dallas Information Systems.
The table below is provided to help Users understand the expectations associated with various scenarios involving data and computing devices:
|UT Dallas Information Systems||Personally Owned Computing Device|
|University Data||• In scope for this Policy
• ISO, OIT, and/or Decentralized IT may have visibility in the course of performing job responsibilities – Users have no expectation of privacy
• UT Dallas has an interest in University Data
|• In scope for this Policy
• ISO has no monitoring capability, nor intent to pursue such capability
• UT Dallas has an interest in University Data, and User is required to cooperate if an investigation of possible risk to University Data is initiated
• UT Dallas has no interest in personally owned data, though personally owned data may be visible to UT Dallas personnel in the course of performing an investigation
• Users are discouraged from placing University Data onto personally owned computing devices
|Personally owned Data||• In scope for this Policy
• ISO, OIT, and/or Decentralized IT may have visibility in the course of performing job responsibilities – Users have no expectation of privacy
• UT Dallas has no interest in personally owned data and existing ownership rights remain unchanged
• With the exception of personally owned data related to a User's job responsibilities (e.g. scholarly works), Users are discouraged from placing personally owned data onto UT Dallas Information Systems
|• Out of scope for this Policy
• ISO has no monitoring capability, nor intent to pursue such capability – Users do have expectation of privacy, provided that University Data is not present
• UT Dallas has no interest in personally owned data
Users shall never use UT Dallas Information Systems to deprive access to individuals otherwise entitled to access University Data, to circumvent UT Dallas information security measures; or, in any way that is contrary to UT Dallas's mission(s) or applicable law.
Users may not intentionally deny access to designated administrators of UT Dallas Information Systems.
Users may not delete logs from systems to hide possible security violations or prevent authorized investigations. This does not apply when done for other purposes, such as de-identifying research data.
Users may be required to complete training on information security, specific to their role in the organization.
Users should report misuse of UT Dallas Information Systems or violations of this policy to their management, to the ISO, or via the Compliance Hotline.
Confidentiality & Security of Data
Users shall access University Data only to conduct UT Dallas business and only as permitted by applicable confidentiality and privacy laws. Users must not attempt to access data on systems they are not expressly authorized to access.
Users shall not disclose Confidential Data or Controlled Data except as permitted or required by law and only as part of their official duties on behalf of UT Dallas.
Confidential Data or other information essential to the mission of UT Dallas should be stored on a UT Dallas-managed network server when possible, rather than on a UT Dallas-owned desktop workstation, laptop, or portable device.
Users are encouraged to store any University Data on UT Dallas Information Systems, rather than personally owned equipment.
In cases when a User must create or store Confidential Data on a local hard drive or a portable device such as a laptop computer, tablet computer, or smart phone, the User must ensure the data is encrypted in accordance with UT Dallas, UT System and any other applicable requirements.
Confidential Data must be encrypted during transmission over unsecured networks (e.g. Internet or hotel wireless network). Users will be provided with tools and processes to send encrypted data over unsecured networks.
Users may not store University Data with a third party storage service (often referred to as "cloud" storage) unless the service has been approved by the ISO. Because some computing devices are configured to automatically connect to potentially insecure remote storage services, Users are encouraged to confirm current settings on any computing devices used to access University Data and disable features they do not intend to use.
Users may not use security testing tools (e.g. password crackers, vulnerability scanners and/or exploitation code) from and/or against UT Dallas Information Systems unless required for performance of official duties on behalf of UT Dallas.
The ISO may temporarily limit or disable network connectivity for devices that pose a significant threat to UT Dallas Information Systems or University Data.
UT Dallas Information Systems may be observed by ISO and/or OIT personnel responding to an investigation or incident, at the direction of UT Dallas's President, UT Dallas Human Resources, UT Dallas or UT System Counsel, and/or law enforcement; or at the direction of UT Dallas Office of Administration when processing requests made in accordance with the Texas Public Information Act.
Incidental Use of UT Dallas Information Systems
Incidental Use of UT Dallas Information Systems must not interfere with User's performance of official UT Dallas business, pose an unreasonable burden on system resources, result in direct costs to UT Dallas, expose UT Dallas to unreasonable risks, or violate applicable laws or other UT Dallas or UT System policy.
Users are encouraged to use personally owned systems, rather than UT Dallas Information Systems, for conducting personal computing and must understand that personally owned content stored on UT Dallas Information Systems may be visible to UT Dallas personnel whose job responsibilities involve the management and monitoring of UT Dallas Information Systems.
A User's Incidental Use of UT Dallas Information Systems does not extend to the User's family members or others regardless of physical location.
Incidental Use may include communications such as e-mails, web pages, and social media posts; if such communications could be reasonably interpreted as expressing the opinion or position of UT Dallas, they should be accompanied by a disclaimer (e.g. "The opinions expressed are my own, and not necessarily those of my employer, The University of Texas at Dallas").
Incidental Use to conduct or promote the User's outside employment, including self-employment, is prohibited unless such use is approved by the User's dean or department head.
Incidental Use of UT Dallas Information Systems that directly results in financial gain to the individual – such as work in support of outside employment or self-employment – is prohibited unless such use is approved by the User's dean or department head in accordance with UT Dallas PP1091, "Conflicts of Interest Conflicts of Commitment and Outside Activities."
Incidental Use for purposes of political lobbying or campaigning is prohibited.
Accessing, creating, storing, or transmitting sexually explicit materials during Incidental Use is prohibited. Questions regarding whether particular content is "sexually explicit material" should be directed to UT Dallas counsel or the UT System Office of General Counsel.
Emails sent or received by Users in the course of conducting UT Dallas business are University Data that are subject to state records retention and security requirements.
Users are expected to use UT Dallas-provided email accounts for conducting UT Dallas business, rather than personal email accounts; Users are encouraged to use personal email accounts for conducting personal communication and business, rather than UT Dallas-provided email accounts.
Emails containing Confidential Data must be encrypted with tools and processes approved by the ISO in order to reduce risk of interception.
The following email activities are prohibited when using a UT Dallas-provided email account:
- Sending an email under another individual's name or email address, except when authorized to do so by the intended User of the email account for a work-related purpose.
- Accessing the content of another User's email account except: 1) as part of an authorized investigation; 2) as part of an approved monitoring process; or 3) for other purposes specifically associated with the User's official duties on behalf of UT Dallas.
- Maliciously sending or forwarding any email that is suspected by the User to contain computer malware. Forwarding to a malware researcher or the ISO for analysis does not represent malicious intent.
- Any Incidental Use prohibited by this policy.
- Any use prohibited by applicable UT Dallas or UT System policy.
Portable and Remote Computing
All electronic devices including personally owned computing devices used to access, create or store Confidential Data or Controlled Data must be protected by mechanisms (e.g. passwords or biometrics) that limit access to authorized Users, in accordance with UT Dallas Information Security Standards.
UT Dallas-issued mobile computing devices must be encrypted.
Any personally owned computing devices on which Confidential Data is stored or created must be encrypted in a manner which protects the Confidential Data from unauthorized access.
University Data created and/or stored on personal computers, other computing devices and/or non-UT Dallas Information Systems should be transferred to UT Dallas Information Systems as soon as feasible.
Because portable computers, smart phones, and other computing devices are targets for theft, Users are expected to take reasonable precautions to physically secure UT Dallas Information Systems or personally owned computing devices containing University Data when theft is likely (e.g. place inside vehicle trunk when traveling, don't leave unattended at a coffee shop or food court, and/or lock in hotel safe when provided).
All remote access to Confidential Data and Controlled Data must be accomplished using an encrypted method approved by the ISO (e.g. VPN, SSH, and/or Outlook Web Access).
Each individual provided with a system account shall maintain securely and never disclose his/her account password or credentials or knowingly permit another individual to access UT Dallas Information Systems via his/her account, except in accordance with a lawful investigation. Any individual who knowingly accesses UT Dallas Information Systems with a user account not specifically assigned to him/her is in violation of this Policy. Similarly, Users may not share individually-assigned access control devices (e.g. Comet Cards, hardware tokens, and/or door keys) unless necessary to preserve life safety.
Computing accounts will be assigned to individuals, except when a shared account is justified by the functions being performed. Accounts designed specifically for a shared purpose or specific system task, such as facilitating data backups or scheduled batch processing, will be granted only in cases when absolutely necessary and will be shared with as few individuals necessary to effectively perform UT Dallas operations.
Computing accounts providing access to UT Dallas Information Systems will only be created when necessary to achieve UT Dallas objectives. Access privileges will be assigned to provide the minimum necessary permission to perform job responsibilities.
UT Dallas Information Systems are subject to risk-based authentication configuration settings defined in Information Security Standards (e.g. password length, complexity, and 2-factor authentication).
Account credentials should not be hard coded into scripts, software code, or system configurations. When hard coding credentials is deemed necessary, system owners will store these files in a secure manner and will maintain sufficient documentation to allow periodic manual changes to passwords or other credentials.
The ISO will administer an annual account sponsorship renewal process, whereby accounts will be verified by responsible management and disabled if no longer necessary or associated with a valid User at UT Dallas.
When employment relationships are subject to change or termination, responsible management will participate in checkout processes defined by Human Resources to ensure timely disabling of system access.
In order to limit the possibility of malicious access, the ISO may disable computing accounts based on reasonable indication that the account has been disclosed to, or compromised by, a malicious third party. The ISO shall assist in re-establishing control of the account by the intended User.
UT Dallas Information Systems access should be designed to maintain separation of duties to reduce the risk of a malicious individual performing conflicting activities (e.g. requesting system access while also approving one's own system access). Compensating controls such as log monitoring and system-enforced thresholds may also be implemented when conflicting duties cannot be separated.
Computer Systems Security
All UT Dallas Information Systems, including production and non-production systems, must be configured and operated in accordance with Information Security Standards.
All UT Dallas Information Systems should be updated with the latest compatible software patches. This includes patches for the operating system and third-party applications. High-priority patches may need to be installed outside of routine change control procedures at the request of the ISO in order to address critical security vulnerabilities.
The ISO may participate at key steps of projects involving access to Confidential Data or Controlled Data. The ISO should assess security controls and notify stakeholders of risks prior to introducing new solutions into production. Costs of security testing, if applicable, will be considered part of the project budget.
All software used at UT Dallas, including commercial and open source, must be used in compliance with End User License Agreements (EULAs). Software requiring fees for usage may not be used in a manner intended to avoid paying such fees.
Harmful or unlicensed software may be removed from UT Dallas Information Systems at the direction of the ISO.
Backup & Recovery
UT Dallas Information Systems are subject to backup procedures and methods to ensure continuity of operations. Data backups must be performed according to a schedule consistent with data retention and destruction requirements appropriate for the data type and classification. Backups must be periodically tested to ensure functionality.
All backup media (e.g. removable backup tapes) stored outside UT Dallas data centers must be encrypted to reduce risk of interception by unauthorized parties and should be stored at a distance sufficiently far from the primary data location to ensure that a regional disaster will not disrupt access to both the primary and backup data simultaneously.
When backup media is retired, it must be destroyed according to Information Security Standards.
Data must be stored and retained according to the UT Dallas Records Retention Schedule. To prevent access to Confidential Data by unauthorized parties, storage media must be destroyed according to Information Security Standards.
Storage media (e.g. hard drives, flash memory, magnetic data tapes, and floppy disks) must be securely overwritten before reuse and physically destroyed at the end of the useful life of the device.
Paper and CD/DVD optical media must be securely shredded in a manner sufficient to prevent reassembly.
UT Dallas-issued mobile computing devices are subject to electronic erase or factory reset procedures before the device is issued to another User or retired from service.
Vendors who host data remotely must provide UT Dallas with a certificate of data destruction upon termination of the contract.
Locations that support access to UT Dallas Information Systems must be protected in accordance with value of the information assets at risk. High-risk locations include, but are not limited to, data centers, server closets, wiring closets, file rooms, and research labs.
Users are encouraged to wear UT Dallas identification in restricted access areas; visible UT Dallas identification may be required at the discretion of a dean or department head.
Users who work in restricted access areas should remain aware of unidentified individuals who may attempt to gain access.
Locked doors protecting restricted access areas should not be propped open if unattended.
Users will maintain a workspace where Confidential Data or Controlled Data is stored in a manner to mitigate risk of observation or theft by unauthorized parties (e.g. locked offices, locked file cabinets, and/or privacy screens).
All third-party vendors that host or access University Data are subject to assessment by the ISO.
Contracts with third parties will include expectations for information security.
Third parties will be expected to protect UT Dallas Information Systems and University Data with security equal to or better than levels defined in this Policy and applicable Information Security Standards.
All third parties performing tasks or data processing for UT Dallas are required to notify UT Dallas immediately if a security incident has occurred, or is suspected to have occurred.
Business Continuity Planning
Individuals responsible for critical operations must maintain a business continuity plan which accounts for facilities, equipment, staffing, and UT Dallas Information Systems needs.
Compliance with all elements of this policy may not be possible in some situations given the tradeoffs between risk, cost, and operational impact. Users may request exemptions to elements of this Policy; requests will be subject to approval or denial by the ISO within 30 days of the request. When applicable, DOs will be asked to accept risks associated with non-compliance. Exemption requests should include an explanation of why compliance with specific Policy elements is not feasible and should describe compensating controls that are in place to reduce risk. Approved exemptions will include an expiration date and be tracked by the ISO.
Exemption requests not approved by the ISO may be appealed to UT Dallas's President.
Instances of noncompliance, or attempted noncompliance, may constitute a security violation that is subject to investigation and possible disciplinary action, civil prosecution, and/or criminal prosecution in accordance with applicable policies and laws.
Violations may result in disciplinary action by Human Resources in accordance with pertinent policies, up to and including termination of work relationships. Students involved in violations will be referred to the Office of Student Affairs. Suspected illegal activities will be escalated to appropriate law enforcement agencies.
This Policy does not create or supersede any existing UT Dallas processes for taking disciplinary action. The ISO, which shall not take direct disciplinary action against a User, will participate in existing UT Dallas processes for taking disciplinary action.
Server and application administrators may be called upon to provide information to support a disciplinary investigation or similar purpose. Accessing emails, logfiles, or other data for investigative purposes (not to be confused with routine operations, troubleshooting, and system management) without proper authorization – particularly in retaliation for whistleblower complaints – is an actionable abuse of privilege. An authorization matrix is posted at the ISO website as, "Procedures for obtaining access to user data."
Per UTS-165, all institutions within UT System must have an Acceptable Use Policy. By acknowledging this Information Security and Acceptable Use Policy, users are acknowledging policies for Acceptable Use.
Users must acknowledge that they received and read the Information Security and Acceptable Use Policy. They must understand and agree that use of UT Dallas Information Systems is conditional upon agreement to comply; noncompliance may result in disciplinary action as outlined above.
Texas Administrative Code 202 (TAC 202)
University of Texas System 165 (UTS-165)
Texas Medical Records Privacy Act
Texas Public Information Act
Family Educational Rights and Privacy Act (FERPA)
Health Insurance Portability and Accountability Act (HIPAA)
Payment Card Industry Data Security Standard (PCI DSS)
Gramm–Leach–Bliley Act (GLBA)
Digital Millennium Copyright Act (DMCA)
Conflicts of Interest Conflicts of Commitment and Outside Activities - UTDPP1091
UT Dallas Records Retention Schedule
Criminal Justice Information Services (CJIS) Security Policy
- Issued: 2015-01-22
- Revised: 2016-06-02